Review of Requirements for the Registration and Regulation of

Proposals

1109. The estimated costs of performing the registration and supervisory (including disciplinary) functions differ for each of the options set out in this Paper.

1110. The following paragraphs outline the estimated costs that the Working Party anticipates would be incurred in implementing the administrative arrangements proposed by the Working Party.

Registration and Supervision

1111. Information provided to the Working Party by the ICAA and ASCPA indicates that, on the basis of them being authorised accounting bodies and jointly performing the registration and supervisory functions, the cost of performing these functions would be approximately $764,000 in the first year and $617,000 in the second and subsequent years. While income from annual renewals and applications is currently expected to be about $470,000 per annum, the ICAA and ASCPA estimate that fees revenue would be $310,000 in the first year and $293,000 in the second and subsequent years.

1112. The Working Party notes that the quantum of the costs associated with the performance of the registration function by authorised accounting bodies will largely depend on the way in which the function is performed by the accounting bodies. If, for example, the registration and supervisory functions can be performed as an adjunct to other functions, for example, the issue of public practice certificates, lower additional costs may be incurred by the authorised accounting bodies.

1113. If the authorised accounting bodies were to assume responsibility for the registration and aspects of the supervision of RCAs, the ASC would continue to incur some expenditure in performing an audit type function on compliance by the authorised accounting bodies with either the terms of the MOU or the conditions under which statutory conferral is made.

1114. Fees for registration and submission of statements would be payable to the authorised accounting bodies. It is envisaged that the quantum of such fees would be a matter for the authorised accounting bodies to determine although the bodies have indicated a reluctance to see any substantial increase in fees beyond their present level arising out of a change in the institutional arrangements in view of the ‘special’ and public benefit nature of auditing and the current funding arrangements.

1115. The Working Party notes that the question of whether authorised accounting bodies should receive additional Government funding or a transfer of resources from Government for undertaking the registration and supervisory functions will be one for the Government and the authorised accounting bodies to negotiate. Nevertheless, both the ICAA and the ASCPA have indicated that they would be unwilling to bear an excess of costs over revenues for the provision of the delegated activities. The Working Party further notes that any submission for funding over and above that which is presently provided by Government under the existing regulatory requirements would have to demonstrate that additional costs incurred by the authorised accounting bodies in performing the functions were the result of increased and improved procedures for registration and supervision and that, in total, costs involved for the registration and supervisory functions exceeded revenue that could be reasonably obtained through the imposition of fees.

Disciplinary Functions

1116. If the CALDB is to be responsible for hearing conduct related disciplinary matters, annual costs no greater than the $312,000 incurred in 1995/96 could be expected. In these circumstances, both the ASC and the accounting bodies could be expected to incur discipline related costs similar to those currently being incurred.

Appendix A

SUBMISSIONS RECEIVED BY WORKING PARTY

Name of individual or organisation	Issues	Discussion Paper	Draft Report
National Corporate Regulation Scheme agencies
Australian Securities Commission (staff comments)	3	3
Companies Auditors and Liquidators Disciplinary Board	3	3	3
Other Government agencies
Australasian Council of Auditors General		3
Australian Financial Institutions Commission	3	3
Insurance and Superannuation Commission	3	3	3
Reserve Bank of Australia	3
Trade Practices Commission		3
Australian Capital Territory Treasury	3
The Audit Office of New South Wales	3
The Treasury (New South Wales)	3
Office of Business Affairs NT Attorney General’s Department	3	3
Northern Territory Auditor General’s Office		3
Queensland Audit Office	3	3
Auditor General (Tasmania)	3
Department of Treasury and Finance (Tasmania)	3		3
Department of Finance (Victoria)	3
Victorian Auditor General’s Office	3
Corporate Affairs Branch WA Ministry of Justice		3
Office of the Auditor General (Western Australia)	3	3
Treasury (Western Australia)	3
Accounting Profession
Association of Taxation and Management Accountants			3
Auditing Standards Board	3
Australian Society of CPAs and The Institute of Chartered Accountants in Australia	3	3	3
The Institute of Chartered Accountants in Australia (ACT Office)	3
Midwest Accountants Group		3
National Institute of Accountants	3	3	3
New Zealand Society of Accountants	3		3
Practising Accountants Centre for Education Inc	3	3
Other Professional and Business Organisations
Australian Corporate Lawyers Association	3
Australian Institute of Company Directors	3	3
Australian Stock Exchange	3
Group of 100	3	3	3
Insolvency Practitioners Association of Australia	3		3
Trustee Corporations Association of Australia		3	3
Accounting Firms
Asset Management Services		3*
Bird Cameron Partners (Canberra)	3
BMO Accountants Group		3
Brown Burns & Co	3
Bye, John W			3
Byfields		3
Alex Campbell & Co			3
Campbell Smith & Associates		3*
Geoff Coleman & Company Pty Ltd			3
Collins Creek Consultants Pty Ltd	3
Coopers & Lybrand	3	3	3
Creagh, Chapman, Barker Pty Ltd		3
Deloitte Touche Tohmatsu	3
Edwards Irvine and Facius Pty Ltd		3*
Ernst & Young			3
Everall Merrett Mann Pty		3
Fleay Gardiner & Associates		3*
Fleming Partners			3
Forsyths			3
Geers & Pusey		3*
Gillard Turner & O’Brien Pty Ltd		3*
Hearne, G F O		3*
Hennessy, Eris M	3
Herries Davidson & Co		3
Hollands & Partners		3
Hudson & Co		3*
R T Kidd & Associates		3*
KPMG			3
Ledger Rutledge & Wilkinson		3
Lee, Timothy		3*
Lillingston Milne		3*
Lovetts			3
Ludwig, Ross		3*
McCleary, Brian			3
McNeil, Marie		3*
Marlow Bluhm		3
Metcalf Spahn	3	3
K J Meyer Pty Ltd		3*
John W Muntz & Co		3*
James Murphy & Co		3
Nipper, M R		3	3
Price Waterhouse	3	3
Reid, Subra and Associates		3*
E. Rochman & Co Pty Ltd			3
Rodda, Graeme		3
Rous & Gamble		3*
Samuel, Martin & Rogerson	3
Shedden & Green Partners			3
Smith, Leslie M		3
Southwell Keely Partners		3
Taits	3
Barry M Thompson & Co		3
Vivian Coetsee & Associates		3*
Walter and Turnbul			3
Weston Woodley & Robertson			3
Other
Craswell, Prof. Allen			3
Hancock, P J (plus P Robinson, J Kestel)		3
Wilkin, John		3	3

* These submissions either are form letters (dealing with the issues of public interest, accountant’s skills and the registered company auditor designation) or incorporate material that has been taken from the form letter.

Appendix B

AUSTRALIAN ACCOUNTING BODIES

B01. As noted in chapter 3, Australia’s accounting bodies have developed comprehensive requirements for entry to membership, the supervision of members and the disciplining of members which apply to all members of the bodies, including those who are RCAs. As many of these requirements exceed the legislative requirements and ASC procedures for the registration and supervision of company auditors, the Working Party believes that the following overview of the requirements of the accounting bodies will be of assistance to readers when they are considering the Working Party proposals.